BLACKBURN WITH DARWEN LOCAL PLAN 2018-2037

GYPSY AND TRAVELLER SITE SELECTION METHODOLOGY December 2020

1. INTRODUCTION

1.1 The Housing Act 2004 places a duty on Councils to assess the accommodation needs for Gypsies and Travellers and make adequate provision for them within its area. The 2015 Planning Policy for Traveller Sites states “Local planning authorities should, in producing their Local Plan:

a) Identify and update annually, a supply of specific deliverable sites sufficient to provide 5 years’ worth of sites against their locally set targets; b) Identify a supply of specific, developable sites, or broad locations for growth, for years 6 to 10 and, where possible, for years 11-15; c) Consider production of joint development plans that set targets on a cross- authority basis, to provide more flexibility in identifying sites, particularly if a local planning authority has special or strict planning constraints across its area (local planning authorities have a duty to cooperate on planning issues that cross administrative boundaries); d) Relate the number of pitches or plots to the circumstances of the specific size and location of the site and the surrounding population’s size and density; e) Protect local amenity and environment.”

1.2 In 2015 the Government changed the definition of “traveller” for planning related purposes so that it would exclude those who have permanently ceased from travelling. The new definition of gypsies and travellers in Planning Policy for Traveller Sites reads:

“Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family’s or dependants’ educational or health needs or old age have ceased to travel temporarily, but excluding members of an organised group of travelling showpeople or circus people travelling together as such.

In determining whether persons are “gypsies and travellers” for the purposes of this planning policy, consideration should be given to the following issues amongst other relevant matters: a) whether they previously led a nomadic habit of life b) the reasons for ceasing their nomadic habit of life c) whether there is an intention of living a nomadic habit of life in the future, and if so, how soon and in what circumstances.”

1.3 To assess the current need for Gypsies and Travellers within Blackburn with Darwen, the Council commissioned a Gypsy and Traveller Accommodation Assessment (GTAA) which was prepared jointly with Hyndburn Borough Council. The Study is available to view on the new Local Plan website here and has informed the preparation of the draft Plan.

1.4 The GTAA identified a need for a minimum of 17 net additional Gypsy and Traveller pitches over the plan period 2018-2037, along with provision for 5 new transit pitches. No need was identified for Travelling Showpeople in the Borough.

1.5 This report summarises how the Council has identified specific, deliverable Gypsy and Traveller sites to meet the first five years’ pitch requirement. These sites will be included as ‘Potential Growth Areas’ within the draft Local Plan for Gypsy & Traveller use.

2. SITE SELECTION PROCESS

2.1 The Council undertook a ‘Call for Sites’ consultation in September - December 2018, inviting agents and landowners to submit details of available sites for development, including those sites suitable to accommodate Gypsy & Traveller pitches. No sites were put forward for Gypsy and Traveller accommodation at this stage.

2.2 Consultation on the Issues and Options Local Plan took place between February and April 2019. One of the consultation questions contained within the document related to whether people agreed with the current policy approach within the Local Plan to Gypsy and Traveller pitch provision. It also allowed for any general comments to be raised. Only one response was received relating to this question from Livesey Parish Council stating that they agreed with the Council’s current approach. There were no other comments relating to Gypsy and Travellers.

2.3 In allocating a site for a specific use within the Local Plan, the Council must be confident that there is a likelihood of that use taking place. It is clear from the fact that only one response has been received through the new Local Plan consultation to date regarding Gypsy and Travellers, as well as from the lack of private sites being put forward through the Call for Sites process that the Council cannot rely on private sites coming forward to meet the identified need. As a result, the Council’s own land has been looked at to identify any appropriate sites for allocation. This will ensure any sites allocated for Gypsy and Traveller use are deliverable.

Site size requirements

2.4 There is limited guidance available on the size of a pitch required for gypsies and travellers, either permanent or transit. However, there is some good practice guidance available on what each pitch should contain, see particularly ‘Designing Gypsy & Traveller Sites: good practice guide’ (DCLG). Although this guidance has been withdrawn, it includes some useful information relating to site design requirements. The Council has used the information contained within this guidance to create a basic site layout to provide an indication of the minimum size of site required.

2.5 For transit pitches, each individual pitch needs to contain the following:

 Space for two touring caravans  Two parking spaces  Water and electricity connections  A 3m buffer around the boundary

2.6 One transit ‘pitch’ can accommodate two caravans, which means that identifying a site for five pitches will actually accommodate up to ten caravans. A basic sketch layout is shown below. At a minimum, a site would need to be around 0.15 hectares to accommodate five transit pitches.

Electricity/water connection (x2) Access road Parking space (x2)

Caravan (x2)

3m buffer

10 metres

2.7 For permanent pitches, each pitch would generally contain the following:

 Space for a mobile home  Space for a touring caravan  An amenity block (containing WC with sink, bath/shower, store room, kitchen/food preparation area, small dining area)  Two parking spaces  At least six metres between mobile homes; and  A 3 metre buffer around the boundary.

2.8 There would also need to be a space for any on-site management facilities, visitor parking and amenity/play space. A basic sketch layout is shown below.

2.9 At a minimum, a site would need to be around 1-1.5 hectares to accommodate 10-15 permanent pitches.

Space for touring caravan

3m buffer Amenity block

Parking space

(x2) 3m buffer 3m

Access road

Amenity space and space for management facilities

Stage 1: Initial list of sites

2.10 The initial stage of site selection involved identifying all Council owned sites that had been identified within the Strategic Housing & Economic Land Availability Assessment (SHELAA), in addition to any further sites the Council considered had potential for Gypsy & Traveller pitches which were not included in the SHELAA. All sites which met this initial assessment are listed in Appendix A

2.11 It is important to emphasise that no other assessment was carried out at this stage to generate the initial list of 34 sites. This means that there were some sites included where there was clearly no potential for use as a Gypsy and Traveller site. However, it was important to ensure that the assessment of sites was as thorough as possible, and that the reason for rejection of sites was set out formally.

2.12 From this initial list of sites, the Council undertook an assessment of the availability of each site for Gypsy and Traveller use. Many of the sites included are being brought forward to meet other identified development needs, such as for housing or employment and so were discounted through this stage of the assessment. Appendix B sets out the reasons for sites not being progressed to more detailed assessments on suitability.

2.13 From this assessment, four sites were considered to be available for development and these progressed onto the next stage of site selection which involved a more detailed assessment of suitability. These sites were Furthergate Plot 7, Blackburn; Junction 4 M65 (Moss Bridge), Darwen; Intack, Blackburn; and land at George Street West, Blackburn.

Stage 2: Detailed assessment of the shortlisted sites

2.14 In order to establish a robust basis for assessing the suitability of sites to accommodate Gypsy & Traveller pitches, a set of criteria were used in the assessment. These criteria are that sites should:

 Have good access to local services and facilities;  Be primarily located within urban areas;  Be in an area of low flood risk;  Safeguard the health of occupiers and provide a satisfactory level of amenity for them, by reference to a range of factors including but not limited to the space available for each family, noise, odour, land contamination, other pollution or nuisance, and the disposal of refuse and foul water;  Have good vehicular and pedestrian access from the highway;  Not give rise to an unacceptable impact on amenity for users in the vicinity of the development, or, in the case of nearby commercial users, result in the imposition of new constraints on the way in which such users can operate their business.

2.15 The Stage 2 assessment also considered any other issues that would affect the suitability of the site, which included the prominence of the site in the local area, the proximity of the site to the existing residential community and the level of/ability to provide screening to the site.

2.16 Another important consideration was flood risk. National planning policy is clear that any development that would involve people living in caravans and mobile homes is not appropriate in Flood Zone 3 or the functional floodplain, and there is no recourse to the sequential test or exceptions test in these cases.

2.17 The following criteria therefore formed the basis of the assessment:

 Highways access  Access to facilities  Neighbouring uses  Environmental considerations (including flood risk)

2.18 In order to ensure each site was robustly assessed, Council officers in Drainage, Public Protection and Highways provided their comments on each site which were included in the proformas (see Appendix B).

2.19 Following the Stage 2 assessment of sites, it was concluded that the Furthergate Plot 7 site was not suitable for allocating for Gyspy and Traveller use. Comments from Public Protection highlighted the site is actively gassing as a result of its former use as a landfill site. In addition, the site is located next to Silicon Engineering, a silicon rubber manufacturer that produces significant fume and odour from their process operations. In light of these issues, it was determined the site would have a significant impact on potential users of the site and would therefore not be suitable for Gypsy and Traveller use.

Stage 3: Finalising sites 2.20 The three shortlisted sites (Moss Bridge, Darwen, George Street West, Blackburn and Intack, Blackburn) were then assessed in more detail through both the site assessment stage of the Sustainability Appraisal work and the Strategic Flood Risk Assessment (SFRA) Level 1 as part of the Local Plan evidence base.

2.21 This evidence work identified a significant part of the site at Moss Bridge (Junction 4 M65) was at risk of surface water flooding. As a result, in line with national guidance, the site was removed as a suitable Gypsy & Traveller site due to potential flood risk.

2.22 Following the detailed assessment stages set out in this report, the two sites identified as being suitable to progress for Gypsy & Traveller use: George Street West, Blackburn and Intack, Blackburn. These are included in the draft Local Plan as ‘Potential Growth Sites’ to provide the specific, deliverable sites needed to meet the Borough’s first five years’ pitch requirement.

2.23 Outline Feasibility Studies have also been prepared for both sites which include indicative site layouts. These are available to view as separate documents.

APPENDIX A: TABLE OF SHORLISTED SITES FOR GYPSY AND TRAVELLERS

Site Address Site Available to progress to detailed site Area assessment? (ha) 1 Furthergate Plot 7, 1.7 Yes - initial assessment suggests site may have Blackburn potential to accommodate Gypsy and Traveller pitches – progress onto assessment of suitability. 2 Site off Junction 4 1.05 Yes - initial assessment suggests site may have M65 (Moss Bridge) potential to accommodate Gypsy and Traveller pitches – progress onto assessment of suitability. 3 Chapels Park North, 2.57 No – Council progressing the site for alternative Darwen use. 4 Chapels Park South, 1.25 No – site being progressed for employment use Darwen and therefore not available. 5 Extension of existing 0.85 No – site already accommodates 20 pitches and site at Ewood, any additional pitches over and above this would Blackburn not be deemed suitable due to Gypsy and Traveller preferences for smaller sites (ideally no more than 15-20 pitches, based on Government guidance). 6 Intack Bus Depot, 0.73 Yes - initial assessment suggests site may have Blackburn potential to accommodate Gypsy and Traveller pitches – progress onto assessment of suitability. 7 Ellison Fold Way 27.62 No – site being progressed for market housing. Phase 2, Darwen 8 Blackamoor Road 2.17 No – site being progressed for market housing. Development Site 9 Fishmoor Drive 1.10 No – site being progressed for market housing. Parcel 2, Blackburn 10 Fishmoor Drive 10.57 No – site being progressed for market housing. Parcel 4, Blackburn 11 Haslingden Road 6.48 No – site being progressed for market housing. (Fishmoor Reservoir) site 12 Holden Fold (Former 17.2 No – site is being progressed for market Darwen Moorland housing. School), Darwen 13 Ellison Fold Phase 1, 1 No - site is being progressed for market Darwen housing. 14 Queens Park Flats, 3.13 No - site is being progressed for market Blackburn housing. 15 Fishmoor Drive 0.5 No - Site is being progressed for market Parcel 5 – Longshaw housing. HOP 16 Land at Pleckgate, 4.45 No - Site is currently in use as playing pitches School, Blackburn and therefore development of the site would not be possible within the Plan period. Also the site, if brought forward, will be more suited to market housing development.

17 Laneside, Blackburn 0.33 No – site is being progressed for market housing. 18 North East Blackburn 3 No - site is being progressed for market – Land off Whalley housing. Old Road 19 Sunnyhurst Centre, 0.8 No - Site is no longer available for development Darwen – is being retained for education purposes. 20 Land off Higher 1.89 No - Due to ecological importance of the site Audley Street, and its designation as a 'Stepping Stone', in Blackburn addition to extensive tree coverage, site will be retained as green infrastructure. 21 Eccleshill Gardens 0.85 No - The site is located within the Green Belt Recreational Ground, and therefore is not a suitable location for Gypsy Darwen & Traveller pitch development. 22 Blackamoor Road 6.82 No - The site will be brought forward for Development Site employment development. 23 TIBS/Former 4 No - Site has been reserved for mixed use Blakewater College, development associated with the hospital. Blackburn 24 Furthergate 5.12 No - The site will be brought forward for Development Plots 2- employment development. 5, Blackburn 25 Furthergate 0.56 No - The site will be brought forward for Development Plot 6, employment development. Blackburn 26 Roe Lee Mill 2 Site, 0.29 No - The site will be brought forward for Blackburn employment development. 27 Dock Street, 0.46 No - The site will be brought forward for Blackburn employment development. 28 Land at Greenbank 3.89 No – Flood issues on site and therefore Road, Blackburn unsuitable to progress for Gypsy & Traveller use 29 Furthergate Phase 1, 4.45 No - The site will be brought forward for Blackburn employment development. 30 Osborne Road, 0.83 No - The site is identified as an important area Blackburn of open space in a densely populated area – this will be retained as open space. 31 School Lane, Guide 0.77 No – Adjacent to employment uses – public protection issues as a result unsuitable for Gypsy & Traveller use. 32 Whitehall Road, 0.82 No – The site is an important open space and Darwen will be retained as such. 33 Site at Junction 5 2.96 No - The site is identified as a strategic M65, Blackburn employment site in the Local Plan and therefore is not available for Gypsy & Traveller development. 34 Land at George 0.32 Yes - initial assessment suggests site may have Street West potential to accommodate Gypsy and Traveller pitches – progress onto assessment of suitability.

APPENDIX B – STAGE 2 ASSESSMENT OF POTENTIAL SITES

SITE 1: FURTHERGATE PLOT 7, BLACKBURN

Site name: Furthergate Plot 7 Settlement: Blackburn Ward: Little Harwood & Whitebirk Location: Within urban area Land type: Mixed Gross size (ha): 1.7 Developable land (ha) 0.8 Current land use: Vacant land Estimated site capacity: Approximately 10 pitches

Biodiversity Part of the site is greenfield and therefore may have some ecological value but no formal designations. Flood Zone 50% of site located within Flood Zone 2, 10% located in Flood Zone 3. River Blakewater culverted underneath the site; pockets of surface water flood risk on the site; High risk of flooding on site. Local Character – No overlooking of the site. Is within established employment area however is screened on all sides. Prominence of site in local area Proximity to existing Is within an established employment area with considerable separation from existing residential community. residential community However, due to its proximity to employment uses, potentially significant impact on amenity of users of the site if progressed for Gypsy & Traveller use.. Access to services Within walking distance to schools/GP surgery/shops – accessible site within the urban area. Site Access Highly accessible site close to Junction 6 of M65 with access to site available off Blakewater Road. Environmental Protection Public Protection highlight the site is a former landfill that is still actively gassing. In addition, it is next to Silicon issues Engineering, a silicon rubber manufacturer that produces significant fume and odour from their process operations. The smell would make it unpleasant to live on the site. There would also most probably be noise issues and as a result they have highlighted that they would object to any planning application on the site. No longer pursue as a potential allocation. Landscape Screening Although there is some natural buffering around the site, it is not considered sufficient to fully protect amenity of future residents from adjacent employment uses.

SITE 2: SITE OFF JUNCTION 4 M65 (MOSS BRIDGE), DARWEN

Site name: Site off Junction 4 M65 (Moss Bridge) Settlement: Blackburn Ward: Darwen East Location: Within urban area Land type: Greenfield Gross size (ha): 1.05 Developable land (ha) 1.05 Current land use: Vacant land Estimated site capacity: Approximately 15 permanent pitches

Biodiversity No formal designations although site is greenfield so has some potential ecological value. Flood Zone Not within any Flood Zone but at risk of surface water flooding (100 year event would cover the site) based off modelling. Basic 2D modelling suggests a 50mm flood level, a FRA/Hydraulic model would be required which highlighted flood levels to design a large portion of risk out; there is a UU surface water sewer, a combined sewer and culvert running through the site. Flooding issues on the site would require further investigation through the SFRA Level 1 at the next stage of assessment. Local Character – No overlooking of site, limited prominence of the site in local area therefore character of the area will be Prominence of site in local protected. area Proximity to existing Separation from existing residential community, safeguarding the amenity of existing residential community residential community and also the potential Gypsy & Traveller community on the site. Access to services Within walking distance to schools/GP surgery/shops, sustainable site. Site Access Potential site access issues – needs investigating further at next stage of assessment. Environmental Protection Potential issue with regards to noise due to location off M65 motorway and Earcroft Way. There would also be issues land contamination challenges due to former mill and reservoir on the site. Landscape Screening Existing natural buffer around the site to protect amenity of potential residents and neighbouring uses.

SITE 3: INTACK BUS DEPOT, BLACKBURN

Site name: Intack Bus Depot Settlement: Blackburn Ward: Little Harwood & Whitebirk Location: Within urban area Land type: Brownfield Gross size (ha): 0.73 Developable land (ha) 0.73 Current land use: Bus depot although some of the site surplus to requirements and available for development Estimated site capacity: Potential to accommodate 5 transit pitches

Biodiversity No formal designations – brownfield land currently in use as bus depot. Flood Zone Flood Zone 1 and therefore at low risk of flooding. Minor risk of surface water flooding on site (100 year at entrance off Accrington Road) although could be designed out relatively simply. Local Character – There is an area of mature vegetation and trees to the south of the site which offers screening and mitigation Prominence of site in local for the existing properties along Accrington Road. The existing mature vegetation adjacent to the entrance at area the north of the site currently screens views of Whitebirk Road. There is little existing vegetation of note along the western boundary that could screen views of the adjacent bus depot. Proximity to existing Site is bounded by residential properties to the east which sit at an elevated position compared to the proposed residential community development site. Appropriate separation distances must be considered within any design proposals. However, there is an area of mature vegetation and trees to the south of the site which offers screening and mitigation for the existing properties along Accrington Road. Access to services Sustainable site within the urban area. Walking distance to schools/GP surgery/shops/services along Accrington Road. Hereford road play area located to the north of the site. Site Access Existing access to the site available off Whitebirk Road. Highly accessible location just off main road network and to the south of junction 6 M65 Environmental Protection Site has been used as a depot since 1800’s when it was the Steam Tramways Depot and therefore potential issues for contamination. Part of the site remains active as a bus depot and therefore potential noise issues which will need to be explored further. Landscape Screening Existing natural buffer (trees) surrounding the site to provide adequate screening to protect amenity of existing community and potential Gypsy & Traveller community.

SITE 4: LAND AT GEORGE STREET WEST

Site name: Land at George Street West Settlement: Blackburn Ward: Blackburn Central Location: Within urban area Land type: Brownfield Gross size (ha): 0.32 Developable land (ha) 0.32 Current land use: Household Waste & Recycling Centre Estimated site capacity: Approximately 5 pitches

Biodiversity No formal designations – brownfield site Flood Zone The site borders a Local Flood Risk Zone. A very small section of the eastern and northern part of the site next to the river is also at risk of surface water flooding and lies within flood zone 2. However, as only about 5% of the site is at risk, it would be possible to reduce this risk significantly locally on the site. Local Character – Site is located within designated employment area (Secondary Employment Area) and therefore surrounded by Prominence of site in local existing employment uses. area Proximity to existing Located within established employment area. residential community Access to services Close to Bank Top District Centre which includes variety of facilities and services, schools etc. Also easy access into Blackburn Town Centre. Site Access Existing site access available off George Street West. Environmental Protection Potential noise concerns from nearby industrial uses. The existing boundary vegetation and stone wall issues boundary treatment may help to mitigate against potential noise and visual disturbances from adjacent industrial units, but further mitigation must be considered within the design. Landscape Screening The existing boundary vegetation and stone wall treatment is an important asset for the site and should be maintained and improved upon to offer screening from adjacent industrial uses and privacy for the proposed users.